Disclosure to the Public by Entities Pillar III
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Disclosure to the Public by Entities Pillar III Data as at 31 December 2018 This document is a courtesy translation into English of the document in Italian approved by the Board of Directors. In case of any discrepancies or doubts between the English and the Italian versions of the Report, the Italian version prevails. Contents Introduction ................................................................................................................................. 4 Risk management objectives and policies ........................................................................ 7 Scope of application.............................................................................................................. 61 Own Funds ................................................................................................................................. 70 Capital Requirements............................................................................................................. 85 Credit Risk - General information regarding all banks .................................................. 97 Credit Risk - standard approach....................................................................................... 113 Credit Risk - IRB approach................................................................................................... 116 Risk Mitigation Techniques .................................................................................................. 140 Counterparty Risk................................................................................................................... 144 Securitisation and Covered Bond Transactions............................................................ 156 Market risk - IMA approach ................................................................................................ 167 Equity exposures..................................................................................................................... 177 Operational risk ...................................................................................................................... 182 Interest rate risk on positions in the banking book ....................................................... 185 Liquidity - Liquidity Coverage ratio................................................................................... 188 Encumbered assets............................................................................................................... 191 Financial Leverage................................................................................................................ 194 Remuneration and incentive systems and practices ............................................ 199 Glossary..................................................................................................................................... 276 Declaration of the Risk Unit Manager.............................................................................. 281 Declaration of the Financial Reporting Manager........................................................ 282 3 Introduction Periodic disclosure provided to the market regarding the Group’s capital adequacy (Pillar 3 Disclosure) Supervisory regulations require that banks fulfil specific obligations to publish information regarding their capital adequacy, exposure to risks and the general characteristics of the systems for identifying, measuring and managing these risks, and to supply information on remuneration practices and policies in order to strengthen the role of market discipline. Since 1 January 2014, the prudential supervisory provisions applicable to banks have been contained in Circular 285 of 17 December 2013, the publication of which was functional to the start of application of the EU legislation (CRR Regulation EU no. 575/2013 and CRD IV Directive 2013/36/EU) containing the reforms of the Basel Committee accords (Basel 3). The subject, as specifically noted in Part II, Chapter 13 of the Circular, is directly regulated by the CRR (Part Eight and Part Ten, Title I, Chapter 3) and by the European Commission regulations containing the technical rules for regulation or enactment. According to the CRR Regulation, banks must publish the information required at least once a year. It is up to the same entities to assess, on the basis of the significant aspects of their activities, the need to publish some or all of the information required more frequently, in particular on the composition of Own Funds and capital requirements. The Banco BPM Group, created on 1 January 2017 by the merger between former banking groups Banco Popolare and Banca Popolare di Milano, already authorised by the Supervisory Authority to use internal methods to calculate capital requirements for credit risk (former Banco Popolare and from 31 March 2018, BPM spa, merged by incorporation with the Parent Company Banco BPM as of 26 November 2018), market risk (former Banco Popolare, Banca Aletti and Banca Akros) and operational risk (former Banco Popolare, Banca Aletti, SGS and BP Property) believes it is appropriate to continue preparing interim reports, also in accordance with the EBA guidelines ("Guidelines on materiality, proprietary and confidentiality and on disclosure frequency under Articles 432(1), 432(2) and 433 of Regulation (EU) No 575/2013"). The present document, entitled Disclosure to the Public by Entities, constitutes fulfilment of the aforementioned regulatory obligations and is drawn up on a consolidated basis. All qualitative and quantitative information at 31 December 2018 is provided below. Information relative to the Banco BPM Group is also structured in the light of the indications and guidelines issued with regards to the Disclosure by the EBA over the last few years. With the 22nd update to Bank of Italy Circular 285/2013, these guidelines became an integral part of supervisory regulations. In particular, these refer to the following areas: EBA/GL/2014/14, on the relevance, exclusivity, confidentiality and frequency of the disclosure, pursuant to articles 432, paragraphs, 1, 2 and 433 of Regulation EU 575/2013 ("CRR"); 4 EBA/GL/2016/11, on disclosure obligations pursuant to part eight of the CRR; EBA/GL/2017/01, on the disclosure of the liquidity coverage ratio, adding to the disclosure on liquidity risk management, pursuant to article 435 of the CRR; EBA/GL/2018/01, on uniform disclosures pursuant to article 473-bis of the CRR, with regards to transitional provisions aimed at attenuating the impact of the introduction of IFRS 9 on own funds. In compliance with the aforementioned disclosure and frequency obligations, the present document is published on the website www.bancobpm.it in the Investor Relations section. All amounts shown in the tables below are stated in thousands of euro, unless otherwise indicated. Treatment of profit for the purposes of preparing the Pillar 3 disclosure Based on the provisions of Art. 26, paragraph 2 of EU Regulation no. 575/2013 of 26 June 2013 (CRR), the inclusion of profits in Common Equity Tier 1 Capital (CET1) is subject to the prior permission of the competent authorities (the ECB), which requires these profits to be verified by the auditing firm. Bank figures and capital ratios illustrated in this disclosure include the economic result at the end of financial year 2018. 5 Capital adequacy ratios at 31 December 2018 Own Funds and capital adequacy ratios 31/12/2018 31/12/2017 A. Capital buffers and requirements Own funds Common Equity Tier 1 Capital (CET1) 7,754,246 9,378,682 Additional Tier 1 Capital (AT1) 133,891 229,660 Total Tier 1 Capital 7,888,137 9,608,342 Tier 2 Capital (T 2) 1,553,803 1,935,926 TOTAL OWN FUNDS 9,441,940 11,544,268 Risk-weighted assets Credit and counterparty risks 56,177,956 67,381,808 Credit valuation adjustment risk 180,633 319,533 Settlement risk 64,884 21,347 Market risk 1,858,688 2,573,112 Operational risk 5,872,577 5,600,641 Other calculation elements 169,328 0 RISK-WEIGHTED ASSETS 64,324,066 75,896,441 B. Capital adequacy ratios (%) B.1 Common Equity Tier 1 Ratio 12.1% 12.4% B.2 Tier 1 Ratio 12.3% 12.7% B.3 Total Capital Ratio 14.7% 15.2% Own Funds and the capital ratios as at 31 December 2018 have been calculated by applying the provisions of the Bank of Italy and the European Central Bank in accordance with Basel III regulations1. At 31 December 2018, own funds totalled € 9,442 million against weighted assets of € 64,324 million, mostly arising from credit and counterparty risks and, to a lesser extent, operational and market risks. The Total Capital Ratio stood at 14.7%; the Group Tier 1 Ratio (Tier 1 Capital to RWAs) stood at 12.3%. The Common Equity Tier 1 Ratio (Common Equity Tier 1 to RWAs) was 12.1%. 1 More specifically, the data has been calculated with consideration for the current legislation and the interpretations issued prior to 6 February 2019, the date on which the Board of Directors approved the quarterly equity and economic statements at 31 December 2018. 6 Risk management objectives and policies Introduction The Banco BPM Group and the companies that belong to the same seek to respect criteria of prudence and reduced exposure to risk in their business activities, as regards: i. the need for stability in the exercise of banking activities; ii. sustainable development in the areas it operates in; iii. their investors’ profile. The process to manage and control the risks assumed by the Group is coordinated by Banco BPM Spa in its dual role as Parent Company and the company where all